Proposed Re-evaluation Decision PRVD2015-01, Glyphosate
Pest Management Regulatory Agency 13 April 2015
ISSN: 1925-0967 (PDF version) Catalogue number: H113-27/2015-1E-PDF
Appendix IIa Registered Commercial Class Uses of Glyphosate in Canada
Canadian mothers! –Health Canada has given you 60 DAYS to respond to the document:
Proposed Re-evaluation Decision PRVD2015-01.
PLEASE USE THE FOLLOWING INFORMATION & THE LINKS BELOW TO SUBMIT INFORMATION!
The most important thing you can tell Health Canada – is current risk reduction measures are not sufficient. You don’t want glyphosate sprayed on your children’s food. At all.
This includes animal feed that is then turned into meat and dairy products that your children eat. This includes any product that is used to manufacture infant formula.
The current re-evaluation is FAULTY because it doesn't look at recently released science.
The re-evaluation states: 'An evaluation of available scientific information found that products containing glyphosate do not present unacceptable risks to human health or the environment when used according to the proposed label directions'.
Health Canada you only evaluated scientific information provided by the registrant - the chemical company. That is NOT all the available scientific information. You are not properly evaluation the risks to human health and the environment.
Health Canada dismisses the IARC findings. Health Canada states: 'The World Health Organization’s (WHO) International Agency for Research on Cancer (IARC) recently assigned a hazard classification for glyphosate as “probably carcinogenic to humans”. It is important to note that a hazard classification is not a health risk assessment. The level of human exposure, which determines the actual risk, was not taken into account by WHO (IARC). Pesticides are registered for use in Canada only if the level of exposure to Canadians does not cause any harmful effects, including cancer. '
1. Health Canada, you can't know the risk because you don't look at recently published studies.
2. Health Canada, you don't know the level of exposure because you don't test glyphosate in food - not in dairy, fruit and vegetables, meat and cereals. Your only testing is private crop testing, this does not reflect what our children are exposed to every day.
3. Health Canada, by ignoring 21st Century science you refuse to acknowledge the damage done to our children's gastric, endocrine and neurological systems, you refuse to look at toxicity of glyphosate based herbicides in relation to cancer - you are failing Canadian children and families.
NOTE: All the studies used by Health Canada to establish are supplied by the registrants - applicants - chemical companies. RITE revieiwed the original Re-evaluation document - Page 250:
B. Studies Considered for the Toxicological Hazard Assessment
LIST OF STUDIES/INFORMATION SUBMITTED BY REGISTRANT
The studies are all OLD INDUSTRY toxicity studies - these are the studies that say 'glyphosate is safe' - Health Canada is hiding behind private, unpublished, old industry (the critical studies giving us our ADI/RfD dated between 1970-2001) studies and ignoring the published recently released studies that demonstrate that glyphosate based herbicides are dangerous at the levels we consume. These old studies, even if they are also used by the WHO, US EPA and Europe, are all private, unpublished corporate paid studies - they are last century's science.
NOTE: Health Canada doesn't want to hear from you. They don't want you to tell them they need to change their ways, that the current status of the re-evaluation document is flawed and not scientific because it only uses SELLER SPONSORED SCIENCE to establish glyphosates 'low toxicity' and that what they are doing is unsafe for your children.
Follow their questions as below as a guide - or submit your own content BEFORE 11 JUNE.
Here is the comment form – with spaces for comment (up to 20 lines) :
(If on Google Chrome download and then email)
3. Science-based comment on health?
a. Health Canada's dismissal of the IARC findings is not science based and fails Canadian families.
b. The full formulation of glyphosate based herbicides are significantly more toxic to human cells. Major Pesticides Are More Toxic to Human Cells Than Their Declared Active Principles. R. Mesnage et al 2014.
c. Your re-evaluation of glyphosate fails to take into account its action as an endocrine disruptor at low levels:
1. Glyphosate alone acts as an estrogen substitute (xenoestrogen) in human hormone-dependent breast cancer cells, stimulating growth at minute concentrations as low as 10-12 (1ppt) Thongprakaisang et al 2013
2. A 24h exposure to a concentration of Glyphosate (in Roundup) at 0.72mg/L caused significant cytotoxicity in vitro. Young et al 2014
3. Glyphosate formulation diluted in water at 1ppb caused severe organ damage, endocrine tumours & pituitary tumours. Seralini et al 2014 republished study.
d. Health Canada is failing to consider the sustantial costs incurred as a result of endocrine disruption: Expert panels achieved consensus at least for probable (>20%) EDC causation for IQ loss and associated intellectual disability, autism, attention-deficit hyperactivity disorder, childhood obesity, adult obesity, adult diabetes, cryptorchidism, male infertility, and mortality associated with reduced testosterone. The Journal of Clinical Endocrinology and Metabolism, 2015, 100(4):1245-55. doi: 10.1210/jc.2014-4324. Epub 2015 Mar 5. As a chelator glyphosate action in soil reduces nutrient availability in our food.
e. Accepted Operator Exposure Levels (AOELs) are outdated and unsafe. They are private unpublished studies from the 1980s and 1990s, this is not good enough.
f. Glyphosate use on human food, including cereals, oilseeds, legumes and vegetables; and animal feed including grains, pasture and silage should be immediately suspended due to toxicity & EDC at low levels.
4. Do you have any science-based comment on the environment?
Environmental and agronomic effects of glyphosate focus mainly as its actions as a chelator of minerals and its contribution to soil degradation - reducing availability of micronutrients, nitrogen, microbial activity.
Effects on soil, crop and plant health: glyphosate use is associated with increase in plant disease. Glyphosate harms soil microbes, reduces nutrient availability. As a chelator of critical metals and micronutrients, glyphosate also then negatively impacts plant enzymes which are vital in the plants immune system. This can lead to increased plant disease. (Professor Don Huber) (Eker, S et al 2006)
Populations of micro-organisms that suppress disease-causing fungi have been found to decrease in soils treated with
glyphosate (Kuklinsky-Sobral J et al 2005) Glyphosate can damage beneficial macro and micro organisms. (Professor Don Huber)
Glyphosate has been shown to interfere with the uptake of essential minerals in agricultural crops leading to nutritional deficiences in human populations (Zobiole LHS et al 2011a) Glyphosate has been shown to reduce nitrogen fixation of plants. (Zobiole et al 2009 doi:10.1016/j.apsoil.2009.12.003)
Diseases of livestock: Scientists and veterinarians are documenting increased infertility, nutrient deficiencies, frequently connected to manganese deficiency. Problems include high levels of stillbirths and birth defects, abnormal bone formations. (Huber) (Kruger et al 2014) (H.Vleiger)
Health Canada cannot properly assess the impact of glyphosate if it only assesses science provided by the registrant.
5. Do you have any comment on the value?
Healthcare burden of these conditions listed in Comment on Health - among the European population, and concluded that EDCs are likely responsible for some 150 million Euros, or 200 billion dollars, in healthcare expenses.
The economic burden and suffering as a result of disease including inflammatory illness, autoimmune conditions and some cancers arising from glyphosate based herbicides is considerable. Science is demonstrating that the health burden of glyphosate desiccation on our food resulting in the levels the Canadian population is exposed to, far outweighs the perceived economic advantages from applications of this endocrine disruptor and carcinogen to Canadians food.
Health Canada currently ignore the impact of glyphosate as an endocrine disruptor and xenohormone, and therefore ignore the burden of health cost.
Furthermore, Health Canada, by dismissing the independent IARC findings ignores the demonstrated toxicity of glyphosate as a probable carcinogen. Health Canada may be aware of original industry studies from the 1980's and 1990's that dismiss tumours at the level declared safe. Atkinson et al 1993b. Lankas & Hogan 1981.
Current exposure levels do not achieve value to the Canadian population - they represent increased chronic disease, endocrine disruption, cancer and result in systemic soil degradation.
Use of glyphosate based herbicides represent a severe cost that is to date, ignored by all governments and regulatory authorities that choose to select seller sponsored science for risk assessment of toxic pesticides.
6. Please provide us with an overview of your opinion and additional comments?
At this stage Health Canada, in its review of glyphosate, appears to be only considering seller sponsored science, science put forward by the applicants, the pesticides corporations.
Health Canada are not considering recently released, published peer reviewed science regarding glyphosate that demonstrates its action as an endocrine disruptor, posing considerable harm at extremely low levels (parts per trillion). Current exposure levels are unsafe. The excuse that Health Canada does not consider the IARC findings because 'level of human exposure, which determines the actual risk, was not taken into account by WHO (IARC)' is scandalous. As of this date Health Canada does not consider science independent of corporations, nor does the Canadian Food Inspection Agency test for glyphosate in food produced for Canadian families. Old outdated, industry science gives you the excuse to not test the food of Canadians, not to consider recently published science, and not to consider the health costs as a result of glyphosate's considerable toxicity - this is scandalous and reprehensible.
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